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41.
It states that several of the reference values used by the MFHR are not
relevant either because they were not applicable at the time of the matters in
question, such as the limit value on PM10, which only became binding in 2005, or
apply to the future, as in the case of the Kyoto objectives, for which 2012 is the key
date, or the IPPC directive, which must be transposed by November 2007. The
Government also refers to the agreement reached in the Council of the European
Union on the draft Directive on ambient air quality (2757th meeting (environment), 23
October 2006) on the possible deferral of the deadline for achieving PM10 limit
values.
42.
The Government also believes that the data quoted by the MFHR has to be
seen in context. From the national perspective, the TPS levels in the KozaniPtolemaida region are comparable to those recorded in other residential areas in
Greece where there are no power plants. Moreover the high particulate
concentrations at regional level are not uniquely a Greek phenomenon but affect all
southern Europe and are the consequence of multiple meteorological and
topographical factors such as the poorer renewal of air masses in the Mediterranean
region, dry soil, less frequent rain, etc.
43.
Finally, the Government disputes the MFHR's interpretation of various
scientific findings and makes the following points:
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Triantafyllou (2000): this study was not concerned with identifying the origin of
the pollution and also found that in 1994 the average annual PM10
concentration in Kozani had fallen below the air quality standard of 50μg/m3,
which it attributes to the installation of new electrostatic precipitators at the
Ptolemais and Kardia power stations;
Triantafyllou (2003): this study records a general downward trend in TSP
concentrations between 1983 and 1988 in eight measuring stations (Amynteo,
Kapnochori, Polymylos, Petrana, DEH Village, Komanos, Akrini and K. Spor),
equivalent to an average decrease of 45.5% between 1986 and 1998, which it
attributes to the DEH's anti-pollution measures;
Triantafyllou (2005): this study does reveal long-term exposure to very fine
particulates (<10 μm) in excess of the limit values. However, the Government
argues that these are emitted from a height of 200 metres, resulting in very
good dispersion and thus very limited effects on respiratory health;
Samara (2005): this study shows that ordinary traffic is the main source of TPS
emissions in Kozani. In support of this, the Government points out that annual
average TPS concentrations in Petrana, close to Kozani, were less than half
the Kozani level. On the other hand, in Klitos traffic linked to lignite mining is
probably a significant source of pollution. The contribution of fly ash to this
pollution ranged from less than 2% in Florina to 16% in Klitos in warm periods
and averaged less than 15% in all sites (other than the 21% in Klitos in the cold
season);
Pelatoli et al (2006): this study shows that TSP limit values (150g/m3) were
only exceeded in Klitos, the site closest to the power stations and the lignite
transporters. Moreover, in the majority or other sites, the highest TSP
concentrations are associated with particular weather conditions.